Managed File Transfer and the PCI Data Security Standards

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1 "The PCI Security Standards Council is an open global forum for the ongoing development, enhancement, storage, dissemination and implementation of security standards for account data protection. The PCI Security Standards Council s mission is to enhance payment account data security by fostering broad adoption of the PCI Security Standards. The organization was founded by American Express, Discover Financial Services, JCB, MasterCard Worldwide, and Visa International." -- The Payment Card Industry (PCI) Data Security Standards (DSS) are intended for use by merchants, financial processors, point-of-sale vendors, and banks, credit unions and other financial institutions that transmit, process and/or store credit cardholder data. This document is intended to assist such companies to understand: (1) how the standards apply to managed file transfer (MFT) products in general, and (2) how the MOVEit MFT software products by Ipswitch can help them to both achieve and demonstrate compliance with the standards. This document begins with overviews of the PCI DSS and the MOVEit Central client and MOVEit DMZ server products, then goes into detail about the individual MFT-related DSS, together with explanations of how the MOVEit product capabilities assist with or enable compliance. PCI Data Security Standards v.1.1 The PCI DSS v.1.1 consists of these twelve critical data security requirements, organized into six sections. 1 Build and Maintain a Secure Network 1: Install and maintain a firewall configuration to protect cardholder data 2: Do not use vendor-supplied defaults for system passwords and other security parameters Protect Cardholder Data 3: Protect stored cardholder data 4: Encrypt transmission of cardholder data across open, public networks Maintain a Vulnerability Management Program 5: Use and regularly update anti-virus software 6: Develop and maintain secure systems and applications Implement Strong Access Control Measures 7: Restrict access to cardholder data by business need-to-know 8: Assign a unique ID to each person with computer access 9: Restrict physical access to cardholder data Regularly Monitor and Test Networks 10: Track and monitor all access to network resources and cardholder data 11: Regularly test security systems and processes Maintain an Information Security Policy 12: Maintain a policy that addresses information security 1 Source: PCI Data Security Standard version 1.1 at

2 MOVEit Central Client MOVEit Central and MOVEit DMZ are Windows-based enterprise-level MFT solutions that can be deployed together or on a standalone basis, depending on whether client and/or server capabilities are required. (Some MFT vendors combine server and client functions in a single product, but Ipswitch offers them in separate products MOVEit Central client and MOVEit DMZ server for security and value reasons.) The MOVEit Central client is a powerful tool that enables IT staff to automate the transfer and processing of files on a scheduled, event-driven, or on-demand basis. Central is an anything-to-anything solution, able to move large files and large numbers of files between virtually any internal or external system, including MOVEit DMZ servers. MOVEit Central typically resides on a company s internal, trusted network. MOVEit Central moves files using easy-to-create tasks scripting or other programming is not required. Tasks can use Central's built-in AS1, AS2, AS3, FTP, FTPS/TLS, HTTPS, SFTP/SCP2 and SMTP/POP3 clients, as well as its ability to copy to the local file system and/or to shared network folders. Tasks can also automatically process files using a variety of built-in functions, including OpenPGP and SMIME encryption, and with sample and custom VBS scripts and the ability to run third-party applications. MOVEit Central also includes several other abilities: an API interface that enables its tasks to be controlled by third-party programs (such as enterprise job or workflow schedulers) using the MOVEit Central API COM component and/or Java class; and the ability to deploy it on a high availability basis, providing automatic, unattended failover from a production to a continuously updated warm-standby copy of MOVEit Central.

3 MOVEit DMZ Server MOVEit DMZ is a security-hardened managed file transfer portal through which applications and end-users can safely exchange files using Web browsers and a variety of MOVEit and third-party secure FTP clients that support any of these SSL or SSH2 encrypted methods: AS2, AS3, FTPS, HTTPS, SCP2, SFTP or TLS. This, together with its unique, built-in, FIPS validated AES encrypted data storage system, enables MOVEit DMZ to support automatic end-to-end encrypted transfer and storage without using PGP. MOVEit DMZ is usually located in a DMZ, a network segment protected by a company s perimeter firewall(s). This location enables secure access to MOVEit DMZ from the local internal network and from the Internet. Unlike some MFT products, MOVEit DMZ is strictly a server; it cannot initiate connections to other systems. As shown by the arrows above, all connections to a MOVEit DMZ must be initiated by a suitable client, which means there is no need to open any firewall ports from the DMZ segment into the internal network. DMZ-based MFT products that push files into the internal network, and MFT products that use DMZ-based secure file transfer proxies, typically require at least one open port from the DMZ into the internal network. MOVEit DMZ also includes several other abilities: an API interface that provides remote, secure, programmatic access to the product s file (and message) transfer, secure data storage, and user database services using the MOVEit DMZ API COM component and/or Java class; French and Spanish language end-user interfaces; and the ability to deploy it on a high availability basis, providing scalability and automatic, unattended failover in a load balanced, multi-production server environment.

4 PCI DSS: Build and Maintain a Secure Network 1: Install and maintain a firewall configuration to protect cardholder data. The MOVEit managed file transfer system was designed for use with the multi-layer, often multi-firewall network described by PCI DSS 1.2, 1.3, 1.4 and 1.5. The MOVEit DMZ secure MFT server was designed to live on a firewall protected DMZ network segment where it would be partially exposed to the Internet. The MOVEit Central MFT client was designed to live on an internal, trusted network, from which it can establish connections to the MOVEit DMZ server through a firewall. The following are the sections of this requirement that are applicable to the MOVEit products and These deal with specific protocols allowed under the standards. MOVEit DMZ and MOVEit Central can perform all of their necessary file transfer functions under the HTTP/S (SSL) and SFTP (SSH2) protocols, both of which are explicitly approved by section Note: When MOVEit uses FTP it is encrypted before being transferred using one of the following file encryption standards: AS3, FTP/S (SSL), PGP, or SMIME. 2: Do not use vendor-supplied defaults for system passwords and other security parameters. For security reasons, the MOVEit Central client and MOVEit DMZ server do not include any "vendor-supplied default" system passwords or other security parameters. The MOVEit installation packages, and the software itself, force the installer/administrator to set their own usernames and passwords during setup and configuration. Note: MOVEit DMZ server has the ability to suggest unique, randomly generated passwords, which may be used or not as desired. The following sections of this requirement are applicable to MFT products : This section says that only one primary function be implemented on each server. The MOVEit products help enforce this requirement by placing all file "collection" services on the server that hosts MOVEit DMZ and all file "transfer initiation" services on the server that hosts MOVEit Central , and 2.2.4: This section is about locking down or "hardening" server platforms. Ipswitch s CISSP and SANS-certified engineers have designed a "SecurityAuxiliary" utility that is bundled with the MOVEit DMZ and MOVEit Central software. This utility performs many common hardening actions against the host platform when the MOVEit software is installed. 2.3: This section requires that all (non-console) administrative access must be encrypted. Administrative access to MOVEit DMZ is via Web browser using HTTP/S SSL encryption. Administrative access to MOVEit Central is via a Windows program using SSL-secured sockets.

5 PCI DSS: Protect Cardholder Data 3: Protect stored cardholder data. MOVEit Central and MOVEit DMZ incorporate defense in depth that provides a unique advantage over other file transfer products in regards to safeguarding stored cardholder data. The MOVEit products were designed from the beginning with their own built-in user authorization and access controls. These enable the MOVEit software to control exactly who can login, and what they can see and do in regards to commands, files, folders, logs and other users. Both MOVEit products were also designed with their own built-in encrypted data storage system, which uses our MOVEit Crypto cryptographic software. MOVEit Crypto has been FIPS validated by the US National Institute of Standards and Testing (NIST) and the Canadian Communications Security Establishment (CSE). MOVEit Crypto was one of the very first cryptographic software modules to earn FIPS validation (Certificate #310 issued March 2003 to Standard Networks, now part of Ipswitch). MOVEit Crypto includes 256-bit AES encryption (used by the MOVEit software to securely store data) and SHA1 hashing (used to protect passwords and encryption keys and to perform file integrity checks). These built-in authentication, access control, and cryptographic systems mean that the security of the MOVEit products, and the data they store, is independent of the security of the underlying OS. The following sections of this requirement are applicable to MFT products. 3.1: Data Disposal. MOVEit Central and MOVEit DMZ are each capable of doing scheduled, automatic and secure deletion of old files and folders in compliance with the National Institute of Standards and Testing (NIST) SP erasure rules so the data cannot be retrieved later. 3.2: Authentication Data Retention. When passwords (or other credentials) are needed to access a remote system, MOVEit Central securely stores them using reversible strong encryption. When passwords are needed for local authentication, MOVEit DMZ and MOVEit Central both use irreversible strong hashes. MOVEit DMZ also has the optional capability to be tied into one or more "external authentication" sources such as LDAP servers to remove the need for any kind of local authentication at all. 3.4: Protection of Stored Data. This section states that strong encryption must be used to protect credit card numbers (a.k.a. "Primary Account Number" or PAN) when storing such data. Unfortunately, most MFT systems lack the native ability to encrypt the data that they store. In contrast, the MOVEit DMZ server and MOVEit Central client both include strong, native encryption. All data received by a MOVEit DMZ server is encrypted before being stored using its strong, built-in, FIPS validated 256-bit AES encryption. MOVEit Central MFT client has the built-in ability to apply PGP, SMIME, and/or AS2 cryptography to the files it handles. 3.5 and 3.6: Cryptographic Key Storage. These sections deal with very technical key storage elements that are beyond the scope of this whitepaper (please contact Ipswitch MOVEit support). Suffice it to say that the MOVEit software fulfills all of these PCI-DSS key storage requirements.

6 PCI DSS: Protect Cardholder Data, Cont. 4: Encrypt transmission of cardholder data across open, public networks. The MOVEit MFT products provide support for a wide variety of encrypted transfer methods that can be used to exchange cardholder data over public networks, including the Internet, and VPN implementations. MOVEit Central client can do transfers using secure FTP over SSL (FTPS), secure FTP over SSH2 (SFTP and SCP2), as well as secure file transfers using HTTP (HTTPS) and the AS1, AS2, and AS3 protocols. Central can also combine file-level PGP or SMIME encryption with unencrypted transport protocols such as FTP and Windows SMB to achieve "encrypted transmission of data" in legacy or migration situations. MOVEit DMZ server supports transfers using secure FTP over SSL (FTPS), secure FTP over SSH2 (SFTP and SCP2), as well as secure file transfers using HTTP (HTTPS) and the AS2, and AS3 protocols. PCS DSS: Maintain a Vulnerability Management Program The MOVEit Central client provides tightly integrated antivirus protection and auditing when installed on a platform running McAfee, Symantec, or Trend AV software. If any of these applications detects a virus, MOVEit Central will immediately and automatically do the following. Stop the transfer. Delete the file on the system that MOVEit Central downloaded it from, or Remember the file characteristics and never transfer it again. Log the name of the file, virus, and AV software along with the time and date the infection was detected and what MOVEit Central did in response. Alert the appropriate persons via . In addition, MOVEit Central client and MOVEit DMZ server both feature tamper-evident audit logs. This means their audit databases are protected by a chain of cryptographic hashes that make it difficult, if not impossible, for someone to add, delete or modify any audit records without being detected. 6: Develop and maintain secure systems and applications. The MOVEit products have been and continue to be developed and supported by Ipswitch MOVEit staff. This is in contrast to many MFT vendors, who outsource development and/or support work to third parties. Ipswitch makes use of a variety of secure code practices to keep the MOVEit software safe, including: tightly controlling and filtering input; limiting access to "need to know" within the application; intentionally separating security from the underlying operating system; storing and using credentials and keys properly; and having government-approved testing laboratories validate the cryptographic components used. Since their initial commercial release in 2001, the MOVEit products have been deployed by numerous high-profile, high-traffic financial institutions and processors including PCI founder Visa International. As a result, the MOVEit products have been frequently audited, probed, and scanned by evaluators, licensees, and third party security consultants hired by them. The results have been exceedingly positive: very few issues have been reported, and each was quickly resolved by the MOVEit support staff.

7 PCI DSS: Maintain a Vulnerability Management Program, Cont. 6: Develop and maintain secure systems and applications. All of the requirements in this section have either already been implemented in the MOVEit products, or are recommended by MOVEit documentation for implementation when the MOVEit software is deployed. The complete list of requirements from developer-centric section 6.5 is repeated below to provide an idea of the kind of precautions that are taken in MOVEit software. 6.5: Web Application Development Security. This section states that the development of web applications should be based on secure coding guidelines (such as those issued by the Open Web Application Security Project), involve the review of custom application code to identify coding vulnerabilities, and cover prevention of common coding vulnerabilities in software development processes, including all of the following : Unvalidated Input : Broken Access Control (for example, malicious use of user IDs) : Broken Authentication and Session Management (use of account credentials and session cookies) : Cross-Site Scripting (XSS) Attacks : Buffer Overflows : Injection Flaws (for example, structured query language (SQL) injection) : Improper Error Handling : Insecure Storage : Denial of Service : Insecure Configuration Management. To maintain the security of the MOVEit products in the field, Ipswitch support regularly posts security updates on the MOVEit support website (managed through the use of MOVEit Central and MOVEit DMZ). Security alerts, as well as news about the results of OS security patch testing, are securely broadcast to licensees using the secure messaging capabilities of the Ipswitch corporate MOVEit DMZ server. All connections to the support site are via secure SSL-encrypted link, and login to the support site requires authentication and prior authorization. MOVEit licensees have the right to deploy patches and upgrades, at no additional charge, under their required annual software maintenance coverage.

8 PCI DSS: Implement Strong Access Control Measures 7: Restrict access to cardholder data by business need-to-know. The MOVEit products allow the specific assignment of folder permissions, protocol access restrictions, IP address restrictions and other limited rights. All of these are typically "no access unless granted" items. MOVEit software also permits the delegation of authority so that an "administrator" need not have control over the entire MOVEit system, but rather only over a subset of folders, transfer tasks, or a group of users. 8: Assign a unique ID to each person with computer access. The MOVEit products encourage the assignment of a unique ID to each person with computer access. One of the most helpful ways that it does this is to allow specific access to a single resource (folder, transfer task, etc.) by multiple users. For example, two users might have "read" access to a folder and a third might have "write" access. This specific assignment of rights to overlapping resources encourages people to use their own credentials rather than a more powerful "shared" account. The following sections of this requirement are applicable to MFT products. 8.2: Authentication Credentials Beyond Username and Password. MOVEit Central client and MOVEit DMZ server support the following additional methods of authentication. Client Keys. Used with secure FTP over SSH2 (SFTP and SCP2) and with PGP encryption. Client Certificates. Used with secure FTP over SSL (FTPS) and HTTPS, AS1, AS2 and AS3 as well as with SMIME encryption. 8.3: Two Factor Authentication. While this section focuses more on network access than file transfer, MOVEit Central client and MOVEit DMZ server are each fully capable of implementing two-factor (and even three-factor authentication) on all of its administrative and file transfer interfaces. 8.4: Credential Protection. The MOVEit products securely protect stored passwords and keys (as detailed in sections 3.2, "3.5" and "3.6"). Both products also use their secure SSL and SSH2 encrypted transport capabilities to securely protect credentials when they are being transferred. 8.5: Password and User Rules. The MOVEit Central client and MOVEit DMZ server products have configurable password and user policies that enable them to fully meet all the rules in this section : Control addition, deletion, and modification of user IDs, credentials, and other identifier objects : Verify user identity before performing password resets : Set first-time passwords to a unique value for each user and change immediately after the first use : Immediately revoke access for any terminated users : Remove inactive user accounts at least every 90 days.

9 PCI DSS: Implement Strong Access Control Measures, Cont. 8: Assign a unique ID to each person with computer access, Cont : Enable accounts used by vendors for remote maintenance only during the time period needed : Communicate password procedures and policies to all users who have access to cardholder data : Do not use group, shared, or generic accounts and passwords : Change user passwords at least every 90 days : Require a minimum password length of at least seven characters : Use passwords containing both numeric and alphabetic characters : Do not allow an individual to submit a new password that is the same as any of the last four passwords he or she has used : Limit repeated access attempts by locking out the user ID after not more than six attempts : Set the lockout duration to thirty minutes or until administrator enables the user ID : If a session has been idle for more than 15 minutes, then require the user to re-enter the password to re-activate the terminal : Authenticate all access to any database containing cardholder data. This includes access by applications, administrators, and all other users. 9: Restrict Physical Access to Cardholder Data. Surprisingly, the MOVEit products can also help companies to address a few physical security requirements. For example, if someone was able to gain physical access to a MOVEit DMZ server, they would be unable to read any of the cardholder data that it has stored because each file is encrypted with its own key and each key is individually encrypted. Below are other examples that MOVEit products can assist with. 9.5: Off-Site Backups. MOVEit Central client and MOVEit DMZ server can easily and reliably handle the secure, automated transfer, processing and storage of large files, and large numbers of files. This enables them to be used to replace some tape-based physical backups : Courier Reliability. When MOVEit products are used to replace tape-based backups, the need to achieve compliance with this section disappears. 9.10: Media Destruction. While the MOVEit products cannot be used to physically destroy media, both MOVEit Central client and MOVEit DMZ server provide NIST compliant data erasure.

10 PCI DSS: Regularly Monitor and Test Networks 10: Track and Monitor All Access to Network Resources and Cardholder Data. MOVEit audit logging capabilities are among the most comprehensive offered by any MFT products. Many only create text-based logs that list little more than sign-ins, file transfers and when they occur. Such logs often have one or more of the following problems. Log Data Security. Text-based MFT logs are often written out to the disk in the clear, which means they can be easily altered with a desktop editor to hide unauthorized activities. MOVEit Central and MOVEit DMZ each have a built-in, commercially licensed database that they write their audit records to. Access to MOVEit databases requires authorization and authentication. To further guard against tampering, the MOVEit products include a cryptographic "hash chain" that provides proof as to whether the records in the databases have or have not been altered. Administrative Log Data. Text-based MFT logs often do not include any record of administrative actions, such as the addition of users, folder permission changes, and other critical security changes. This makes it difficult or even impossible to discover any unauthorized administrative changes. The MOVEit products write detailed records to their secure databases of all administrative activities. Ease of Use. Text-based MFT logs often must be processed by a third-party "log parser" in order to yield meaningful information. MOVEit products have the native ability to provide ad-hoc audit views. They also include built-in reports and customizable reports that enable administrators to quickly and easily track and monitor their MOVEit products without having to use a third-party "log parser". The following sections of this requirement are applicable to MFT products : User Information. These three sections cover being able to link specific actions to specific users, what sort of actions should be audited, and the information the records should contain. MOVEit DMZ server supports the unique user account per person concept in section 10.1 (see also #8) and exceeds the what to log and how much information to log rules in sections 10.2 and : Time Synchronization. MOVEit products support time synchronization between computers, and provide utilities and documentation to perform this operation using standard time protocols. 10.5: Audit Data Protection. This section includes the following MFT-relevant sub-sections : Access Restriction. This section covers providing restricted access to audit records. Unlike MFT products that use text-based audit logs, MOVEit Central and MOVEit DMZ record audit data to their built-in, commercially-licensed, access-controlled databases. These provide protection against unauthorized users that may gain access to or control of the underlying operating system. Access to MOVEit audit records is controlled so that people can only see events that relate to their organization and/or the groups, users, folders and transfer tasks under their control : Tamper Protection. This section covers the need to safeguard audit records from unauthorized modification. The MOVEit products address this by controlling access to the data (see section ), by employing a cryptographic "hash chain" that checks file integrity to prove whether the data has been altered or not, and by issuing alerts if tampering is detected.

11 PCI DSS: Regularly Monitor and Test Networks, Cont. 10: Track and Monitor All Access to Network Resources and Cardholder Data, Cont : Record Duplication. This section recommends the prompt copying of audit records, either to a centralized server or to media that is difficult to alter (such as a printed paper trail). MOVEit Central and MOVEit DMZ provide instructions about how their audit records can be either sent to a centralized server (via SysLog or SNMP) or spooled out to a print file : Integrity Monitoring. Using file integrity monitoring and change detection software to monitor for audit record changes is required by this section. As mentioned in section , MOVEit products do automatic file integrity monitoring and will issue alerts if problems occur. 10.6: Record Reviews. This section requires regular review of audit records, and recommends that such reviews be automated. MOVEit Central and MOVEit DMZ have the built-in ability to provide ad-hoc audit data views, and to generate over 90 pre-defined reports covering file transfers, secure messages, user status, system performance, storage status and security. Reports can be run on-demand or on a scheduled basis, and can be generated in CSV, HTML, or XML formats. The MOVEit products support automated reviews through their ability to integrate with centralized monitoring (see section ). In addition, both products support the creation of custom reports, which can feed information into specialized systems used to detect particular anomalies. 10.7: Record Retention/Deletion. MOVEit products automatically purge their logs after a configurable time period, and can be set to automatically retain purged logs in an archive-friendly format for long-term storage. 11: Regularly Test Security Systems and Processes. As discussed in section 6, Ipswitch encourages MOVEit Central and MOVEit DMZ licensees to regular inspect and scan their MOVEit test and production systems. The MOVEit products also work with properly configured third-party application file change detection software as suggested in section 11.5.

12 PCI DSS: Maintain an Information Security Policy 12: Maintain a Policy that Addresses Information Security. The MOVEit Central and MOVEit DMZ product documentation describes collections of configuration options, especially collections of security options, as "policies." This was a deliberate choice of terminology. MOVEit policies are designed to let licensees configure their software to enforce their corporate policies. The following sections of this requirement are applicable to MFT products and : Daily Operations. This section addresses daily security operations, including user account maintenance and log review procedures. MOVEit products provide maintenance-oriented administrative interfaces designed to manage hundreds of transfer tasks (MOVEit Central client) and thousands of users (MOVEit DMZ server). "Show audit logs for selected user" and other contextsensitive options like look-up boxes aid the day-to-day security management of the MOVEit products, as does the automated generation and delivery of pre-configured and custom security reports : Alert Monitoring and Analysis. The MOVEit Central and MOVEit DMZ products each write to event logs, which can be sent to SysLog, SNMP, or other central monitoring facilities : User Management Delegation. MOVEit Central allows administrators to delegate control of specific transfer tasks to specified individuals, and MOVEit DMZ administrators are able to delegate control over groups of users and their folders to specific group administrator users : Partner PCI-DSS Compliance. This section addresses the need for PIC DSS compliance by business partners that your company exchanges cardholder data with. Many financial institutions and processors (including one of the PCI Security Standards Council founders) use MOVEit products. In Conclusion The MOVEit products provide a comprehensive set of security and operational capabilities that can help companies to achieve and demonstrate their compliance with, especially in the critical areas of secure cardholder data storage, access control, and audit records. That is one of the reasons that there is a significant installed base of MOVEit products amongst financial processors and banks, credit unions and other financial institutions in North America and Europe. Details on requesting a live MOVEit demonstration or onsite evaluation and/or a pricing proposal can be found by calling the Ipswitch MOVEit Sales staff directly or by visiting the company s public website. Note: While Ipswitch is a Participating Organization of the Payment Card Industry Security Standards Council, this document is not intended as a comprehensive guide for determining a company s PCI DSS compliance.

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